I recently read a communication being circulated by Food and Water Watch which was apparently intended to dispel "rumors circulating the internet about H.R. 875 The Food Safety Modernization Act". I fully appreciate FWW and indeed have benefited from their important work (I think the Factory Farming Map on their website is one of the best examples of effective communication on our current struggling Agricultural Paradigm). I find, however, on this issue that they are missing some of the nuances in this proposed legislation. I write this not from any pejorative point of view but more from that of a respectful and collaborative stakeholder. I hope that it is received in the same spirit.

Response to: "Myths and Facts about HR 875 (and S425)"

I find it peculiar that the organizations who should be vetting this proposed legislation (who actually seem to be partial advocates of said) seem to have no knowledge of the shoot first ask questions later record of State and local agencies around the country at the behest of the FDA and USDA. Trent Hendricks; Mark Nolt; Manna Storehouse; Sharon Palmer; Etc. In California AB 1735 which established a max 10 coliform limit on Raw Milk (the same limit as pasteurized milk) was recommended by CDFA to "simply comply with fed regulations for interstate shipment". Seemingly innocuous until you bother to notice that Raw Milk cannot be shipped interstate, which rendered the recommendation an outright lie. It didn't matter. The legislators were tricked (they said so themselves in session) but the bill was signed by the governor and stands as law today (and the very vocal consumers and two commercial producers had absolutely no say in the matter).

The first caution of the FDA at the onset of the recent and very serious Salmonella outbreak was to stay away from raw milk, eggs and meat (not peanut butter cookies which was the actual threat). Unfortunately it is nothing new for the FDA to forsake REAL FOOD for NOVELTIES.

This current federal legislation lacks specificity which is the problem. It poses as regulation for the larger food industry but doesn't exclude the small and local operator. I'd probably feel very different if I didn't know that the USDA and FDA had a track record of influence, favoritism and indeed leadership by AGRI-Business. My considerable analysis has left me with the opinion that these agencies have become trade organizations rather than the watchdog for human and environmental health that they should be. I do not trust an agency which has a history of championing the very questionable rBST and a pendulous policy regarding high fructose corn sweetener. I'm not diminishing the good they do and have done, I just trust a good farmer more than most of the questionable, reductionist science that has ushered us into the current struggling agricultural paradigm. I think congress needs to consult the actual farmers rather than intellectual property attorneys on issues that will change their lives let alone their customers.

The important aspects of this proposed legislation (i.e.: proper manufacture, storage, handling, best practices etc.) need to happen beyond the farm and should be the responsibility of the industry that is necessitating it. The responsible operator who processes a few head a week and direct sells it to ME at a farmers market or in his farm store, and the very responsible CSA operator who brings me my MIXED BOX of fresh, local, organic vegetables (that are actually touching each other in the same box) shouldn't have to pay for the sins of the 12,000 hog CAFO, or factories pumping out tankers of "peanut paste" who created the problem.

I would gladly recommend a competent panel who could help correct the current congressional vision. I don't know of a farmer who doesn't know where all of his animals are and ear tags and brands are already pervasive. If they want to "rfid" an animal do it when it hits the feedlot that way I can be sure my children won't ingest it. If they want to make it mandatory for animals that are intended for export? Great. Make it the responsibility and burden of the exporters not me, my family and countless others who don't want any part of that system. Leave those of us who have struggled and are struggling, without the help and in spite of the government, to create a humane and survivable agricultural paradigm out of legislation that is claiming to address industrial food safety. If they want to include us, they need to give us a seat at the table and be prepared to listen.

The "FACTS" about this proposed legislation is that it most definitely could be used to turn all of the "MYTHS" into a hellish reality.

I recommend that people actually READ THE TEXT OF THESE BILLS!!!!!! within the context of the history of this country.